Closed call for evidence

Business Rates and investment: Call for Evidence

Published 26 November 2025

Foreword

Economic growth is the central mission of this government. We will increase the UK’s economic growth rate, and deliver higher living standards in every part of the country, through a focus on stability, investment and reform.

This Call for Evidence focuses on how reform of the business rates system can be used to incentivise and secure more investment by Britain’s businesses.

We are delivering our manifesto commitment to rebalance the business rates system by introducing permanently lower tax rates for over 750,000 retail, hospitality and leisure (RHL) properties, worth nearly £900 million of support per year. Large distribution warehouses, such as those used by online giants, will contribute around £100m more in 2026/27. This additional revenue will directly support in-person retail.

The Chancellor has always been clear that we want to go further. We published an Interim Report in September to set out what we will do next to meet our objectives of delivering a fairer business rates system that supports investment and is fit for the 21st century. This Call for Evidence is the next stage on that journey of reform.

Several infrastructure ratepayers, including airports, have told me about the barriers the business rates system – and in particular their valuations on receipts and expenditure – has presented for their long-term investment decisions. I am committed to ensuring that these sectors have the long-term predictability and stability they need to invest, providing confidence to investors and enabling capital-intensive sectors to drive sustainable economic growth across the UK. And I am clear that providing more certainty for those businesses who rely on this methodology is a priority.

Dan Tomlinson, Exchequer Secretary to the Treasury

1. Introduction

The government is committed to creating a fairer business rates system over the course of this Parliament that protects the high street, supports investment, and is fit for the 21st century. The government is delivering its manifesto commitment to support the high street by introducing two new, lower multipliers for retail, hospitality and leisure (RHL) properties with Rateable Values below £500,000, funded by a new, high-value multiplier for properties with an RV of £500,000 or above from April 2026.

At Autumn Budget 2024, the government published a Discussion Paper^{[footnote 1]} inviting stakeholders to work with us on plans to further transform the system. The Transforming Business Rates: Interim Report^{[footnote 2]}, published 11 September 2025, summarised findings from this engagement and set out aspects of the system that have been determined as priority areas for further potential reform:

A new ‘slab’ to ‘slice’ approach – exploring moving from the current tax structure, where a single multiplier is paid on the full RV, to one where each multiplier only applies to the RV above the relevant threshold

• Enhancing Small Business Rates Relief (SBRR) to support business growth and investment
• Enhancing Improvement Relief once more data is available to establish how it is currently being used
• Exploring ratepayer concerns over the receipts & expenditure methodology and options to address these ahead of the 2029 revaluation
• Exploring the possible benefits of shortening the Antecedent Valuation Date (AVD) in the future
• Using the merger of the Valuation Office Agency (VOA) with HMRC to pursue administrative changes that help ratepayers

The government also committed to continue to work with business property owners and Local Authorities to consider how the effectiveness of Empty Property Relief can be improved.

This Call for Evidence represents the next step in exploring how the reforms identified above could be taken forward, to further incentivise and increase investment. It seeks to gather more detailed evidence on how the business rates system influences business investment decisions. This evidence will be used to inform policy development and design.

The government is committed to an open and collaborative process with stakeholders and welcomes contributions to help shape a system that better supports investment and economic growth.

Business rates play a fundamental role in local government funding, providing a stable source of revenue that is used in turn to fund critical local services. Any reforms to the tax will be designed to ensure the stability of public finances.

This Call for Evidence covers the following areas:

• Chapter 2: Further information about you or the stakeholders you represent
• Chapter 3: The role of business rates in investment decisions
• Chapter 4: Transforming Business Rates: reforms to incentivise investment
• Chapter 5: Valuations on the receipts and expenditure (R&E) methodology

In relation to Chapter 5, the government has heard from a small number of ratepayers that aspects of this valuation approach have made it challenging to predict future rates and provide a stable context for long-term, high-value investment essential for infrastructure across the UK. The government is especially interested in receiving representations from businesses with long-term, high-value capital expenditure and their representatives. The government is seeking to address issues raised ahead of the 2029 revaluation which may be progressed separately to the wider business rates reforms.

2. About you

This Call for Evidence builds on the findings of the Transforming Business Rates: Discussion Paper and asks stakeholders for more detailed evidence on how the business rates system influences investment decisions. The government is interested in hearing from a wide range of sectors to support further policy development.

Chapter 5 of this document focuses on the receipts and expenditure (R&E) valuation methodology. For this section, the government would be particularly interested in hearing from infrastructure sectors and others valued on R&E with long-term, capital-intensive investment requirements.

All responses will be treated confidentially in line with the privacy notice set out in Chapter 6.

Questions

1) In what capacity are you responding?

• As a business
• As a Business Representative Organisation
• As a local authority
• As a property owner
• As a rating Agent
• Other (please provide details)

2) Please provide details of the business or body you represent.

3) Where in England are you based?

• East of England
• East Midlands
• London
• North East
• North West
• South East
• South West
• West Midlands
• Yorkshire and the Humber
• National
• Other (please provide details)

4) What sector are you representing?

5) How many properties do you occupy?

6) What is the approximate cumulative Rateable Value (RV) of your property portfolio?

7) Do you own some or all of the properties your business occupies? Please provide details of the breakdown.

8) If you are representing an individual business:

• What is the size of your business?
  • Micro (10 employees or fewer)
  • Small (50 employees or fewer)
  • Medium (250 employees or fewer)
  • Large (over 250 employees)

9) If you are a Business Representative Organisation, what types of businesses do you represent?

10) If you are a landlord, how many properties do you own?

11) If you are a landlord, what types of businesses do you typically lease properties to?

3. The role of business rates in investment decisions

The government is determined to remove barriers to investment for businesses and boost economic growth. To provide stability and predictability for business, the government is committed to ensuring a competitive and sustainable main rate of corporation tax by capping it at 25 per cent for the duration of this Parliament. This stability is designed to boost investment as set out in the Plan for Change.

The government is also introducing permanently lower business rates multipliers for qualifying RHL properties from April 2026. Unlike the current RHL business rates relief, which was introduced on a temporary basis and has an annual cliff-edge, this will provide RHL businesses with long-term certainty and support. This was the first step to transforming the business rates system, and we are now interested in views on what further steps can be taken to provide further certainty in the business rates system to further boost investment.

One of the major themes that emerged from the Transforming Business Rates Discussion Paper was an impression that the business rates system acts as a barrier to investment. As a property tax, it is a feature of the system that improvement to a property, or expansion to additional properties, will increase the value of property and the subsequent business rates liability.

Not all investments lead to an increase in RV. As a rule of thumb, if investments in a property are of a scale that would be reflected in rents, then they are likely to result in an increase in RV. There are also a number of exemptions that exist within the system, particularly for most plant and machinery if used as an integral part of a business process.

Generally, the occupier of a property is liable for business rates. However, the government is aware that business rates will affect the incentives for both occupiers and property owners to invest and improve their property. The government is therefore interested in understanding the extent to which the current system aligns with how investment decisions are made in practice.

In response to the Discussion Paper, stakeholders highlighted the potential to improve investment incentives through changes to the tax rate (otherwise known as the multiplier), the tax structure, and reliefs within the system.

The government also committed to engage with ratepayers over what administrative improvements they would most benefit from. Alongside wider feedback on the role of business rates in investment decisions, the government is interested in hearing further evidence about how the administration of the system can be reformed to support business investment, including the appeals and revaluation processes.

This section seeks input on:

• Evidence on how features of the system have affected investment in practice – for example, information on where the business rates system has influenced specific decisions or instances where investment has been delayed, reduced, or redirected.
• Evidence on the relative significance of business rates alongside other financial and non-financial factors influencing business investment in the UK

Questions

The government is interested in understanding the real-world impacts of the business rates system and requests, where possible, that you provide detailed information and/or case studies to support the development of reforms.

12) In your business or sector, are property improvements typically undertaken by the property owner or the occupier?

13) In your business or sector, do property investments typically occur on existing premises, or do other constraints require relocation or the acquisition of new property?

14) What is a typical investment in your business or sector that affects your business rates? Please provide specific examples (for example, capital-intensive projects, expanding floor space, opening a second site or moving to a bigger property) including relevant financial figures and other specific details.

15) What is the typical lifecycle for these investments and their major decision points?

16) How do business rates specifically influence investment decisions versus other factors? For example, other elements of the tax system, UK competitiveness, borrowing costs, labour costs, regulatory requirements, expected timeframes in which to see additional profit. If possible, please provide examples of specific investment decisions.

17) How do business rates factor into your decisions about property ownership, development, or refurbishment?

18) How do you factor revaluations into business planning (at an individual property level and across your portfolio)? If possible, please provide examples.

19) What are the benefits and downsides of a system where the property occupier is liable for business rates, versus the owner?

20) What changes could be made to the administration of the system to support business investment?

4. Transforming Business Rates: reforms to incentivise investment

The Interim Report set out several features of the business rates system that the government would consider for reform to improve the operation of the business rates system. This section invites feedback on some of these areas to better understand the impact that reforms would have on investment.

This section seeks input on:

• The tax structure (moving from ‘slab’ to ‘slice’)
• Small Business Rates Relief
• Improvement Relief
• Empty Property Relief

The tax structure (moving from ‘slab’ to ‘slice’)

Business rates currently operate by applying a single multiplier to the entire RV of a property to determine its rates bill – which is often referred to as a ‘slab’ method of calculation. This approach means that when a property’s RV crosses a threshold, the higher multiplier applies to the entire RV.

The government is committed to a progressive business rates system, where higher value properties pay more. The government believes there may be merit in moving to a ‘slice’ system for business rates, where the RV is split into slices (or brackets, bands) and each portion is taxed at its own, different rate. The government believes this would create a more positive environment for businesses to operate, and it would also bring business rates more aligned with other taxes such as Income Tax and Stamp Duty Land Tax (SDLT).

While not a direct comparison, the previous ‘slab’ nature of SDLT created distortions in the housing market where a disproportionate number of transactions were occurring just below the threshold levels^{[footnote 3]}. The nature of business rates is different, as a recurrent property tax, where a property’s RV is determined by the VOA using rental evidence, and the government would like to ascertain whether there is evidence that a ‘slice’ structure would have a positive impact on business and investment.

This Call for Evidence is not intended to consult on the thresholds and rates of a ‘slice’ structure. There are multiple ways that the tax schedule could be designed, which would have an impact on ratepayers’ bills and the revenue raised from the system. As a principle, tax rates and thresholds are announced by the Chancellor at fiscal events. Any policy design would need to ensure that the approach is fair, progressive and maintains continuity for local government funding.

Case studies provided below set out the difference between the current ‘slab’ system and a ‘slice’ system. To do this, we have used the multiplier structure which will be in effect from April 2026. As the multipliers are adjusted at every revaluation, and would change dependent on the policy design, the rates used are purely illustrative.

Table 1. Multiplier structure from April 2026

Small business RHL multiplier, RHL properties only, RV below £51,000	Small business multiplier, Non-RHL properties, RV below £51,000
Standard RHL multiplier, RHL properties only, RV £51,000 - £499,999	Standard multiplier, Non-RHL properties, RV £51,000 - £499,999
High-value multiplier, All properties, RV £500,000 and above

Case study: moving from the small business to standard multiplier

A non-RHL property with an RV of £50,000 undergoes property improvements worth £2,000, increasing its RV to £52,000 and into scope of the standard multiplier.

Scenario	RV	‘Slab’ structure	‘Slice’ structure
Pre-improvement	£50,000	£50,000 x 43.2p = £21,600	£50,000 x 43.2p = £21,600
Post improvement	£52,000	£52,000 x 48p = £24,960 (+£3,360 bill increase)	(£50,999 x 43.2p) + (£1,001 x 48p) = £22,512 ( +£912 bill increase)

Case study: moving from the standard to the high-value multiplier

A non-RHL property with an RV of £495,000 undertakes property improvements worth £10,000, increasing its RV to £505,000 and into scope of the high-value multiplier.

Scenario	RV	‘Slab’ structure	‘Slice’ structure
Pre-improvement	£495,000	$495,000 x 48p = £237,600	(£50,999 x 43.2p) + (444,001 x 48p) = £235,153
Post improvement	£505,000	£505,000 x 50.8p = £256,540 (+£18,940 bill increase)	(50,999 x 43.2p) + (£499,001 x 48p) + (£5,000 x 50.8p) = £240,092 ( +£4,940 bill increase)

These case studies demonstrate that a ‘slice’ system would soften the bill increase associated with the change in RV, as different slices are taxed at different rates. The examples above assume the rates are the same in both scenarios to demonstrate the effect of the current system. The government will consider the appropriate rates and thresholds, and the interaction with other possible reforms, as policy development progresses.

Small Business Rates Relief

Small Business Rates Relief (SBRR) provides 100% relief for businesses occupying a single property with an RV of £12,000 or less, with tapered relief for properties with an RV between £12,000 and £15,000. The relief is generally not available for ratepayers that occupy more than one property, subject to some specific exceptions.

In response to the Discussion Paper, stakeholders reported that the single property condition acted as a ‘cliff-edge’ in the system which disincentivises small business expanding into a second property. At Budget 2025, the government announced it would give small businesses an additional two years of relief when they open a second premises. This will triple the current SBRR ‘grace period’ which allows businesses to retain SBRR when they expand, giving them more certainty and confidence to grow.

Stakeholders also requested that the SBRR thresholds were increased. The government is interested in how steep increases in liability, when SBRR is reduced, impacts on investment.

Case study: loss of SBRR

A non-RHL property with an RV of £12,000 undertakes property improvements worth £1,500, increasing its RV to £13,500. The occupier is eligible for 100% relief prior to improvements and 50% relief after.

Scenario	RV	Bill before SBRR	Bill after SBRR
Pre-improvement	£12,000	£12,000 x 48p = £5,760	100% relief = £0
Post improvement	£13,500	£13,500 x 48p = £6,480 (£720 bill increase due to RV)	50% relief = £3,240 (£3,240 bill increase due to RV and loss of relief)

The government will consider how SBRR should work in a ‘slice’ system if there is sufficient evidence to suggest that ‘cliff-edges’ are having a detrimental impact on business investment.

The government also wishes to seek views on the tax treatment of short-term lets. Currently, a property is eligible to pay business rates (instead of council tax) if, in the past year, it was available to rent for at least 140 nights and actually rented out for at least 70 nights. It will also be eligible for SBRR if it meets the other qualifying criteria.

The government recognises the value of positive investment that supports local economies and genuine small businesses. However, concerns have been raised about SBRR being used by second home owners whose main aim is not to operate a local business but to manage tax liabilities.

The government wants to support businesses investing and growing and wants to ensure that any reliefs in the business rates system are appropriately targeted.

Improvement Relief

Improvement Relief (IR) was introduced on 1 April 2024 to ensure ratepayers do not face higher business rates for 12 months following qualifying property improvements. IR is designed to encourage investments in property by providing a 12-month relief for qualifying property improvements.

In response to the Discussion Paper, stakeholders reported that IR did not provide sufficient incentive to invest, due to investment cycles often spanning 3 or 5 years. Many stakeholders also felt that the scope of eligible improvements needed to be expanded to include improvements made by those not in occupation of the relevant property. We will work with business on the case to address this once more data is available to establish how IR is currently being used.

Empty Property Relief

Empty Property Relief (EPR) operates by providing owners of empty non-domestic properties with 100% relief for the first 3 months (or 6 months for industrial properties) after a property becomes vacant. If the property remains empty once the relief period ends, the owner must pay the property’s full business rates liability. Should the empty property be occupied again for a period of 13 weeks or more, it becomes eligible for another period of EPR when it falls empty again. The 13-week period of occupation required to be eligible for another period of EPR is known as the ‘reset period’. The relief is mandatory meaning Local Authorities must grant it, with conditions of what qualifies as occupation and beneficial occupation being based on caselaw.

EPR is intended to give landlords time to find suitable tenants for their properties before they become liable to pay business rates. It recognises that certain properties such as industrial building are harder to let and therefore provides 6 months of relief for these properties. However, the government has heard from stakeholders that the current design does not always meet this objective.

In response to the Discussion Paper, stakeholders reported that EPR does not sufficiently account for refit periods, does not provide adequate time for property owners to find new tenants for their properties, and requires landlords to pay rates on unprofitable buildings which they have not been able to lease.

The government is also aware that EPR is a source of business rates avoidance, including schemes such as “box shifting”, a practice where boxes are moved in and out of vacant properties to secure relief. At the 2024 Spring Statement, the period of reoccupation was extended to disincentivise avoidance. Local authorities have continued to highlight EPR as a significant source of business rates avoidance and they have called for reform to tackle this.

The government recognises the importance of a system where everyone pays their fair share and is committed to taking the necessary action to address business rates avoidance and evasion. The government not only believes that avoidance is unfair, but that the abuse of EPR undermines its goal of bringing empty properties back into use. This discourages investment and allows commercial properties that could otherwise support business activity and growth to remain vacant. This also makes it difficult for the government to balance the need to provide support for owners of empty properties against the importance of preventing avoidance.

Questions

21) Do you have any specific examples where ‘cliff-edges’ in the system have been, or will be an impediment to investment?

22) What types of investment would be supported by a move to a slice-based system?

23) What are the wider benefits or downsides of a slice-based tax?

24) What types of improvements have you considered, but not taken forward because of business rates? Where possible, please provide specific examples where Improvement Relief (IR) has factored into these decisions.

25) Are there any other aspects of IR that you would like to make the Government aware of that would support investment?

26) To what extent does Empty Property Relief (EPR) influence your business’s decisions to acquire, hold, invest in, or dispose of empty properties?

27) What are the main factors that contribute to bringing an empty property into use within your sector? Please provide details.

28) The government is committed to tackling avoidance, while also ensuring that EPR supports business investment. How can the government best meet those aims through reform?

29) EPR has a reset period of 13 weeks. What are the typical lease durations of occupants of non-domestic properties?

30) What is a typical number of days per year that short-term lets are (a) available to let and (b) actually let?

31) What evidence is there that SBRR is being used by second home owners whose main aim is not to operate a local business but to manage tax liabilities?

32) How could SBRR be reformed to limit its use be second homeowners who are not mainly operating a local business while maintaining support for those who are?

33) Does the current system for monitoring and enforcing which short term lets qualify for business rates work effectively?

5. Valuations on the Receipts and Expenditure Methodology

The government has heard concerns from a small number of ratepayers whose properties are valued on receipts and expenditure (R&E) for the purposes of business rates. These focused on challenges in predicting the outcome of an R&E valuation, making decisions around long-term, high-value investments more difficult.

Initial engagement suggests that these concerns are focused around a few sectors with unique business models and regulatory arrangements – for example, large infrastructure with substantial capital expenditure requirements over decades-long investment horizons. These sectors require a significant scale of capital investment to remain competitive and make a notable contribution to the UK economy. They are crucial for the growth mission, make our country more productive, and link up our priority growth sectors with each other and the world – making us all better off.

The government would like to hear from these ratepayers on options it could put in place within the business rates system to support these investments. The government also welcomes feedback from all businesses valued on R&E, their agents, and tax specialists.

While R&E produces suitable valuations for many businesses, the government is committed to exploring the concerns raised by these businesses in particular, and options to improve predictability and stability – for the next revaluation and over the longer term.

The government understands that concerns include:

• difficulty in predicting valuation outcomes and accurately forecasting future liabilities
• the risk that valuations can be highly variable for businesses in which investment levels are high and vary over multi-year cycles
• limited communication and transparency of the process that determines a property’s rateable value, creating uncertainty for investment returns

Pre-List Discussion (PLD) is a non-statutory process where ratepayers for the most complex properties (or their representatives) are invited by the Valuation Office to discuss their valuation before it is finalised. This approach gives ratepayers the opportunity to share information, review the application of the R&E methodology to their property, and forecast future liability. However, the government has heard suggestions that the pre-list discussion process could be improved, including the user experience, tone and frequency of communication, understanding of the evidencing of valuations, and the time commitment required from accountants and executives.

This section seeks input on:

• the extent to which R&E practice and procedure has impacted investment decisions and business plans
• experiences of the pre-list discussion process and how it could be improved to improve transparency and predictability
• what the government could do to support predictability and stability, enabling investment for properties valued on the R&E methodology

The government is seeking to address issues raised ahead of the 2029 revaluation. The government will aim to conclude this work in sufficient time before pre-list discussion commences for the next revaluation and this may be progressed separately to the wider business rates reforms.

Box 5.A What is ‘Receipts and Expenditure’ and when is it used?

Business Rates is a property tax which is based on an estimate of the rental value of a property at a specific date in time –the ‘Antecedent Valuation Date’ (AVD), which for the 2026 list is 1 April 2024. To estimate the rental value, the Valuation Office Agency (VOA) uses three main valuation methods:

• The Rental Comparison
• Receipts and expenditure (R&E)
• Contractor’s Basis

Each of these are recognised in case law and by professional bodies such as the Royal Institution of Chartered Surveyors (RICS) and the Institute of Revenues, Rating & Valuation (IRRV). The availability of evidence determines which is used. For the majority, this will be the rental comparison method. However, this relies on recent and reliable rental transactions from a pool of comparable properties. When there is insufficient rental information and a property is occupied to achieve a profit, the R&E method is used.

Although the primary valuation method used to value a property can change depending on the availability of suitable rental evidence, properties that are usually valued using R&E include hotels, theme parks, utilities and airports.

R&E seeks to estimate what a hypothetical tenant would be prepared to rent a property for by considering the financial potential of the property. These calculations, sense checked against other similar properties, are based on a reasonable expectation of the income that can be generated from that property (the ‘fair maintainable trade’), less the working expenses. The remainder – the ‘divisible balance’ – is the sum available to be shared between the hypothetical landlord and tenant.

The ‘tenant’s share’ needs to provide a return on the tenant’s capital employed and a reasonable reward to reflect risk and profit. The ‘tenant’s share’ is then deducted from the ‘divisible balance’ to leave the ‘landlord’s share’ or the rent payable. This remaining amount is adopted as the property’s RV, which is the basis of business rates liability.

Because R&E valuations reflect the trading conditions and profitability of each occupier’s undertaking at a particular AVD, the RV (and Business Rates liability) will be responsive to changes in markets and economic outlook between different AVDs.

There is no one-size-fits-all approach to R&E valuations for business rates – the required capital investment or the return that investors need on that capital vary significantly between properties. There are some advantages to this flexibility: informed by data shared through pre-list discussion, valuers can make judgements and adjustments that reflect specific property and business characteristics. However, the government has received feedback from a small number of sectors that the element of valuations that require a valuer’s judgement, such as the reasonable return on capital for the tenant’s share, can be difficult to predict – making valuation outcomes difficult to forecast.

When tax liability is uncertain and challenging to forecast, businesses cannot appropriately price risk, making it more difficult to determine Return on Investment, secure financing/investment, and green-light growth. This matters most for businesses whose investments have decades-long payback periods.

The government is committed to exploring options to enable and encourage investment through improving the transparency, predictability and stability of the business rates system.

R&E valuations and impact on long-term, high-value investment decisions

Questions

34) Has the process and methodology of your R&E valuation impacted your ability to plan and/or implement your investment decisions, either for the 2026 revaluation or previous revaluations? Please include:

a) Detail on the projects, for example timescale, location, planned spend, and why you planned to make that investment

b) Any impact on consumers, other businesses, or your local community of changes to investment plans

c) Any impact on the wider economy and growth, trade, tourism, regional regeneration or connectivity

d) Where your liabilities have changed, how you have decided between reducing/increasing investment and passing through additional costs or savings to your customers and why

35) Is there evidence that valuer judgements make outcomes on R&E more unpredictable than other methodologies? If so, please explain.

36) Are there elements of the methodology or its application which make your rateable value challenging to predict? If so, which elements and why are they challenging to forecast?

37) What approaches would provide you with greater predictability and stability for your valuation? Please include:

a) Why this approach would provide greater predictability

b) Any downsides and mitigations, such as less responsiveness to market conditions or specifics of your property

38) What are the advantages and disadvantages of more direct government involvement in valuation, such as intervention to prescribe aspects of a property’s valuation?

39) Is there a different approach to valuation or calculating your rateable value that would provide a more appropriate basis for business rates liabilities, and why?

40) Are there aspects of the property tax system and valuation in other countries you either operate in or directly compete with that better enable high-value, long-term investment? If so, what are they and why are they effective?

41) Are there wider changes government should consider to the business rates system that would better enable high-value, long-term investment?

The pre-list discussion process and transparency

To enable investment, tax needs to be transparent. That means that businesses should understand how their bill was calculated. The R&E methodology relies on the occupier’s financial information. Pre-list discussions, where this information is shared and its application to valuations is discussed, often feature in R&E valuations. These discussions should provide an opportunity for ratepayers to understand how their valuation has been reached.

For particularly complex, large, or highly specialised properties, the pre-list discussion process allows businesses to work with the VOA, e.g. by providing specific information, to secure an accurate valuation. There is no statutory duty on the VOA to carry out pre-list discussions and whom they engage is by mutual agreement.

Pre-list discussion should, and can, be a win-win. For government, working closely with the businesses that own complex hereditaments gives valuers access to the information needed to make accurate and bespoke valuations. For businesses, greater and earlier transparency over rateable values and the ability to discuss how their information is used should provide greater flexibility.

The government wants the pre-list discussion process to work for both valuers and businesses, so welcomes views on how it can be improved, and how valuations can become more transparent.

Questions

42) Does your business take part in pre-list discussion with the VOA?

43) How easy is it for your business to share the necessary / requested information with the VOA to support an accurate valuation on complex points? Please include:

a) whether your business has enough time

b) whether requests for information are compatible with your existing financial reporting arrangements

c) whether you understand how the evidence is used and why it is required

44) Which areas of the pre-list discussion process supported your ability to understand your valuation and ensure it was accurate?

45) Which, if any, elements of the pre-list discussion process could be improved and why?

46) How can government and the VOA better communicate with ratepayers to build confidence and predictability into the system?

6. Next steps

Ways to respond

There are several ways to respond to this consultation. Please follow https://www.smartsurvey.co.uk/s/businessratesinvestmentcfe/ to complete as a Smart Survey. Alternatively, enquiries and responses can be sent to transformingbusinessrates@hmtreasury.gov.uk.

Timelines

This consultation will open on 26 November 2025 and close on 18 February 2026 at 23:55.

All responses will be analysed in depth, but it will not be possible to give substantive replies to individual representations.

Privacy notice

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The personal data will only be made available to those with a legitimate need to see it as part of the call for evidence process.

We sometimes issue calls for evidence in partnership with other agencies and government departments and, when we do this, this will be apparent from the branding and wording of the call for evidence itself. For joint calls for evidence, personal data received in responses will be shared with these partner organisations in order for them to also understand who responded to them.

If you elect to complete the digital form, this will be conducted using SmartSurvey, an industry-leading online survey provider with the highest standards of data security. As with other organisations processing personal data, SmartSurvey is subject to data protection compliance requirements. Although SmartSurvey uses an automated system, the responses you give will not lead to any decisions being made about you and they will not have a direct impact upon you. In this context, SmartSurvey acts solely as a data processor under instruction from HM Treasury and will not use your personal data for any purposes other than to provide the service to HM Treasury. For more information on how SmartSurvey handles respondents data, please refer to their privacy policy here - https://www.smartsurvey.co.uk/company/privacy-policy

As the personal data is stored on our IT infrastructure, it will be accessible to our IT service providers. They will only process this data for our purposes and in fulfilment with the contractual obligations they have with us.

How long we hold the personal data for

Responses submitted via the Smart Survey digital form will only be kept by Smart Survey for as long as we need them. Once the deadline for completion of the survey has passed, all responses will be transferred from SmartSurvey to HM Treasury.

We will retain the personal data until our work on the call for evidence is complete and no longer needed. Identifiable details will be removed from responses where it is necessary to retain responses beyond the end of the call for evidence.

Your data protection rights

You have the right to:

• request information about how we process your personal data and request a copy of it
• object to the processing of your personal data
• request that any inaccuracies in your personal data are rectified without delay
• request that your personal data are erased if there is no longer a justification for them to be processed
• complain to the Information Commissioner’s Office if you are unhappy with the way in which we have processed your personal data

How to submit a data subject access request (DSAR)

To request access to your personal data that HM Treasury holds, please email: dsar@hmtreasury.gov.uk

Complaints

If you have concerns about Treasury’s use of your personal data, please contact our Data Protection Officer (DPO) in the first instance at: privacy@hmtreasury.gov.uk

If we are unable to address your concerns to your satisfaction, you can make a complaint to the Information Commissioner at casework@ico.org.uk or via this website: https://ico.org.uk/make-a-complaint.

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